Partnership Classification for Tax Purposes. Each Member recognizes ------------------------------------------- and intends that for federal income tax purposes the Company will be classified as a partnership, and the Members will not make any election or take any action that would cause the relationship of the Members under this Agreement to be excluded from the application of all or any part of Subchapter K of Chapter 1 of Subtitle A of the Code or from any successor provisions to Subchapter K under the Code or from any similar provisions of applicable state laws.
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Samples: Members Agreement (Ebs Pension LLC), Members Agreement (Ebs Litigation LLC)
Partnership Classification for Tax Purposes. Each Member recognizes ------------------------------------------- and intends that for federal income tax purposes the Company will be classified as a partnership, and the Members will not make any election or take any action that which would cause the relationship of the Members under this Agreement to be excluded from the application of all or any part of Subchapter K of Chapter 1 of Subtitle A of the Code or from any successor provisions to Subchapter K under the Code or from any similar provisions of applicable state laws.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Gramercy Capital Corp)
Partnership Classification for Tax Purposes. Each Member recognizes ------------------------------------------- and intends that for federal income tax purposes the Company will be classified as a partnership, and the Members will not make any election or take any action that would cause the relationship of the Members under this Agreement to be excluded from the application of all or any part of Subchapter K of Chapter 1 of Subtitle A of the Code (as defined in Appendix A) or from any successor provisions to Subchapter K under the Code or from any similar provisions of applicable state laws.
Appears in 1 contract
Partnership Classification for Tax Purposes. Each Member recognizes ------------------------------------------- and intends that for federal income tax purposes the Company will may be classified as a partnershippartnership if so determined by the Board of Directors, and the Members will not make any election or take any action that which would cause the relationship of the Members under this Agreement to be excluded from the application of all or any part of Subchapter K of Chapter 1 of Subtitle A of the Code Tax Code, or from any successor provisions to Subchapter K under the Tax Code or from any similar provisions of applicable state laws.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Capmark Finance Inc.)
Partnership Classification for Tax Purposes. Each Member recognizes ------------------------------------------- and intends that for federal income tax purposes the Company will be classified as a partnership, and the Members will not make any election or take any action that would cause the relationship of the Members under this Agreement to be excluded from the application of all or any part of Subchapter K of Chapter 1 of Subtitle A of the Code or from any successor provisions to Subchapter K under the Code or from any similar provisions of applicable state laws.
Appears in 1 contract
Samples: Members Agreement (Ebs Building LLC)